Law School Case Brief
Klocek v. Gateway, Inc. - 2000 U.S. Dist. LEXIS 21854 (D. Kan. Sep. 6, 2000)
Each plaintiff in class action diversity action must meet the jurisdictional amount in controversy; aggregation is allowed only if plaintiffs unite to enforce a single title or right in which they have a common and undivided interest.
Plaintiff William S. Klocek filed a putative class action lawsuit in federal district court against Gateway, Inc. ("Gateway") and other defendants. The lawsuit stemmed from Klocek's purchase of a computer from Gateway. Gateway filed a supplemental motion to dismiss and compel arbitration. Gateway asserted that the district court lacked diversity jurisdiction under 28 U.S.C.S. § 1332(a) because Klocek could not in good faith claim that the amount in controversy exceeded $ 75,000. In response, Klocek stated that based on lack of subject matter jurisdiction, he joined in Gateway's motion to dismiss. Klocek further stated that he filed his complaint in reliance on a ruling from a federal appellate court which allowed a plaintiff to aggregate class claims for punitive damages to meet the amount in controversy requirement; that ruling, however, was later abrogated by another decision from the same appellate court.
Should the court grant the motion to dismiss?
The court granted Gateway's motion to dismiss for lack of subject matter jurisdiction; the court did not address Gateway's request to compel arbitration. The court noted that while a plaintiff was not necessarily required to specify an exact amount of punitive damages, he must allege enough facts to convince the court that recoverable damages bore a reasonable relation to the minimum jurisdictional requirement. In light of Klocek's concession that the court lacked subject matter jurisdiction, the court found that Gateway's motion to dismiss should be sustained.
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